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  • Essay / Banking: The key role of the banking system in...

    However, the use of the banking system remains a chosen technique for the procedure of money laundering in trying to exploit the vulnerabilities of the structure of the banking system and “intelligence” gaps. As the FCA highlights, systematic failures in banks' anti-money laundering and, more specifically, inadequate anti-money laundering governance structures and oversight, risk assessment processes inadequate or poorly calibrated IT systems, poor management of sanctions control alerts and transaction monitoring, poor identification of the source of wealth and the origin of funds, inadequate risk management of foreign PEPs , inadequate due diligence on correspondent banks, questionable judgments leading some firms to accept higher levels of money laundering risk, facilitate money laundering